Stakeholder Engagement Plan€¦ · 1.4 General Social Context ... mass media. During the hearings, any participant has the right to express his or her opinion, ... External stakeholders

CEZ DISTRIBUTION BULGARIA 1 JULY 2016

CEZ DISTRIBUTION BULGARIA AD

Stakeholder Engagement Plan

2016-2019 Investment Program

July 2016

Prepared for:

European Bank for Reconstruction and Development

One Exchange Square

London

EC2A 2JN


TABLE OF CONTENTS

CEZ DISTRIBUTION BULGARIA AD ............................................................................................................... 1

1 INTRODUCTION .................................................................................................................................. 3

2 PUBLIC CONSULTATION REQUIREMENTS AND STAKEHOLDER ENGAGEMENT TO DATE ..................... 7

3 IDENTIFIED STAKEHOLDERS AND COMMUNICATION RESPONSIBILITIES............................................. 9

4 STAKEHOLDER ENGAGEMENT PROGRAM .........................................................................................13

5 GRIEVANCE MECHANISM ..................................................................................................................19

Annex A: Stakeholder Contact Details

Annex B: Public Grievance Form


1 INTRODUCTION

1.1 Overview

This Stakeholder Engagement Plan (SEP) provides the requirements and applied

processes for stakeholder engagement and public consultation, stakeholder

identification and grievance mechanism planned for CEZ Distribution 2016-2019

Investment Program in Western Bulgaria.

This document is intended for public disclosure and will be made available in

Bulgarian language by CEZ Distribution.

Please do not hesitate to contact us in case of any queries, comments or suggestions

that you may have in relation to this SEP or to company’s operation using below

contact details. Thank you.

regular mail or in person: CEZ Distribution, 159, Tsarigradsko shose Blvd.,

Sofia, 1784, Bulgaria;

phone number: +359 700 10 010;

e-mail: [email protected];

webportal: www.cez-rp.bg.

In case specific projects included in the 2016 – 2019 Investment Programme are

classified by the environmental authorities as having potential significant impact on

the environment, CEZ Distribution will produce and disclose to the public the project

level Environmental and Social Action Plans (ESAPs), Non-Technical Summaries

(NTSs) and Stakeholder Engagement Plans (SEPs).

1.2 Objectives of Stakeholder Engagement Plan (SEP)

The primary objective of the SEP is to map out the strategy for engaging the various stakeholder groups and public in CEZ Distribution’s activities related to the projects included in the 2016-2019 Investment Program. The SEP identifies and describes the key CEZ Distribution stakeholders, summarizes the process of how consultation will work, how feedback or comments will be taken into account and how any grievances will be handled.

1.3 Background of CEZ Distribution operations

CEZ Razpredelenie Bulgaria AD (“CEZ Distribution” or “the Company”) is part of

CEZ Group in Bulgaria (“the Group”), operating in the country starting 2005. CEZ

Group comprises the companies CEZ Bulgaria (the company coordinating CEZ

Group’s activity in the country), CEZ Distribution, CEZ Electro (power supply

company), CEZ Trade (energy trading company) and TPP Varna (a 1260 MWh

thermoelectric power plant).

The Company is the successor of Electrorazpredelenie Stolichno AD,

Electrorazpredelenie Pleven AD and Electrorazpredelenie Sofia Oblast AD as result of

mailto:[email protected]


a privatization process finalised on 18 January 2008. Starting 29 January 2008 the name

of the Company is CEZ Razpredelenie Bulgaria AD (CEZ Distribution).

While the Assignment refers to CEZ Distribution, references to CEZ Bulgaria are also

included in the present report given the relevant role of this company in providing

management services and support to all companies within the group including CEZ

Distribution.

CEZ Bulgaria coordinates and provides management support and consultancy to the

Group companies ensuring a uniform approach to policies and strategies across the

Group. Services provided by CEZ Bulgaria to the Group companies include

Communication and Public Relations, Logistics, Procurement, Financial Services,

Human Resources, Legal Support, Information and Communications Technology, etc.

CEZ Distribution is a public company listed on the Sofia Stock Exchange. It is majority

owned by CEZ a.s. 67% while the remaining 33% of its stocks are in the hands of minor

shareholders. The company is the legal successor of Elektrorazpredelenie Stolichno.

CEZ Distribution owns all the power distribution assets of CEZ Group in Bulgaria after

the 2007 unbundling of the Group’s electricity production and distribution activities in

line with EU requirements. The Company’s activities include operation, maintenance

and development of equipment for electricity distribution between power producers

and consumers.

The Company operates the following main facilities:

29 km overhead High-Voltage (HV) (110 kV) transmission lines;

33 km underground HV (110 kV) transmission lines;

17,068 km overhead Medium Voltage (MV) transmission lines;

7,311 km underground MV transmission lines;

22,898 km overhead Low Voltage ( LV) transmission lines;

9,385 km underground LV transmission lines;

26 HV/MV substations;

15,929 MV/LV distribution stations;

19,200 MV/LV transformers;

2,108,145 installed electric meters.

To address the increased pressure for energy efficiency, the Company initiated a

programme of gradual implementation of new technology on the existing worn grid

infrastructure. CEZ Distribution is in process of obtaining finance of its 2016-2019

Investment Program from the European Bank for Reconstruction and Development

(EBRD). The 2016-2019 Investment Programme represents a continuation of this

currently ongoing modernization plan initiated in the previous years.

The 2016 -2019 Investment Programme comprises numerous projects including low

and medium voltage transmission lines (overhead and underground), underground

high-voltage transmission lines, substations upgrades, electrometers and switch


changes, electrical switchboards overhaul, relocation of electrical switchboards,

equipment investments, buildings repairing/ maintenance, implementation of

environmental measures, connection of new consumers to the network. The investment

programme does not include any projects related to above-ground high voltage (110

kV) transmission lines.

CEZ Distribution has the obligation to acquire part of the facilities it operates, in the

frame of a mandatory buyout. This buyout is considered as part of 2016-2019

Investment Programme. While the cost associated with the Investment Programme

(including the mandatory buyouts) was incorporated into the household energy

distribution tariff, this did not result in a significant affordability impact.

1.4 General Social Context

CEZ Distribution is headquartered in Sofia and provides power supply in ten regions

in Western Bulgaria: Sofia City, Sofia District, Pernik, Kyustendil, Blagoevgrad, Pleven,

Lovech, Vratsa, Montana and Vidin regions.

Those ten regions cover an area of about 39,084 km2 and have an overall population of more than 2 million inhabitants living in 1,560 villages and towns including the Bulgarian capital Sofia. CEZ Distribution Bulgaria employs 2,611 staff (February 2016 data), of which 21% are

women. 2605 persons are full-time employees while 6 are working part time.

Wage levels in the Company are determined by the specific requirements and

responsibilities for the position and are not in correlation with the gender of employee.

The average wages within CEZ Distribution are higher than the medium salary in

Bulgaria (of approximately EUR 450 /month) and at the same level with average

salaries within the sector.

CEZ works actively with local and central authorities and is deeply involved in

communities’ social programs within all the ten regions. The Company’s activities


include environment protection, rehabilitation of kindergartens, schools, children’s

playgrounds and parks, support for local communities, support for projects for

improving of urban environment, volunteer labour, donation of furniture and

electronics, sponsorship for sport competitions, exhibitions, and other sponsorship

activities.

The Company operates under the following principles of the internal communication:

Every CEZ employee has two roles – a client of internal communication and a source of external communication. Effective internal communication will bring long-term reputation benefits to CEZ group of companies in Bulgaria;

CEZ management should ensure that employees understand and share the company mission, vision and will work for its goals;

At each stage of the communication it should be clear – what is the problem, how it will be resolved and who is responsible;

The responsibilities in the internal communication require different expertise and thus a clear terms should be drawn to allow the Public Relation (PR) and Human Resources ( HR) departments to collaborate effectively for the best results;

Effective communication channels and messages are crucial for the staining of trust between CEZ management and employees.


2 PUBLIC CONSULTATION REQUIREMENTS AND STAKEHOLDER ENGAGEMENT

TO DATE

2.1 Bulgarian legal requirements for public consultation

The Bulgarian legislation states that the public should be informed about the projects

which have a potential significant impact on environment, to have the opportunity to

comment on the information provided to it during the development/discussion of the

project. Such projects are subject to the full procedures for Environmental Impact

Assessment (EIA) and the related public consultation procedures.

The EIA process in the Republic of Bulgaria is controlled at the national level by

Chapter 6 of the Environmental Protection Act (EPA) and Ordinance on the conditions and

order for carrying out an EIA. These above legislative documents are transposing the EU

EIA Directive (85/337/EEC, amended and supplemented with Directive 97/11/EC,

Directive 2003/35/EC, and Directive 2009/31/EC - collectively codified by Directive

2011/92/EU and Directive 2014/52/EU).

Projects subject to mandatory EIA procedure are listed in Annex 1 of the EPA, while

projects listed in Annex 2 of the EPA are subject to EIA screening (i.e. authorities judge

whether the specific project has to pass an EIA procedure or not). According Annex 1

of the EPA, only overhead power lines with voltage equal or exceeding 220 kV and

with length equal or exceeding 15 km are subject to obligatory EIA procedure. The

investment programme of CEZ Distribution does not include such projects and the

Company confirmed that they have never had such projects.

In any case, Bulgarian legislation requires the project developer to officially notify the

municipalities and Regional Environment and Water Inspectorates on the territories of

which the project will be developed.

Generally, the main organisational form of determining the public opinion is public

hearings. Public hearings are organized by the project developer, are announced in

newspapers in local languages with 30 days in advance and announce availability of

the EIA Report, the modalities to review the documents and submit the comments and

the details on public hearing (location, date, hour etc.).

Participants of public hearings include interested public, public and non-governmental

organisations and associations, local executive and representative bodies,

governmental bodies authorised to make relevant decisions, mass media. During the

hearings, any participant has the right to express his or her opinion, address questions

related to the project. The results of public hearings shall be recorded in the Minutes of

Public hearing which will be attached to the permitting documentation and considered

by authorities in the process of decision making.

In addition to the public hearings, various public announcements should be posted at

appropriate locations like the company website, on Regional Environment and Water

Inspectorate website, website of the municipality, announcements board at the

municipal building or in newspapers.


2.2 Stakeholder actions to date by CEZ Distribution

All of the 2016-2019 Investment Programme’s projects developed by CEZ Distribution

to date were considered by the environmental authorities to not pose a potential

significant impact on the environment. Hence, the projects are subject only to short EIA

procedures for which public hearings are not required. The projects were disclosed to

the public mainly through public announcements in media and announcement boards

at the respective local mayor offices.

CEZ has not received any comments related to environmental or social issues as a

result of such announcements for projects conducted so far as part of the 2016-2019

Investment Program.

Data on scheduled maintenance activities, extension of networks, rehabilitation of

facilities etc. are regularly announced by the company using printed media, radio, TV

or other available channels.


3 IDENTIFIED STAKEHOLDERS AND COMMUNICATION RESPONSIBILITIES

Stakeholder engagement is coordinated by the Public Relations and Customer Care

Departments of CEZ Bulgaria.

External stakeholders for the 2016-2019 Investment Programme were identified in line

with CEZ Bulgaria Communication Strategy and the communication plans. They were

mapped among groups and individuals that will potentially be impacted by or can

have influence on the investment programme.

Company’s stakeholder groups as identified by CEZ Bulgaria include:

1. State institutions, administrative bodies, Energy regulator, National ombudsman,

local and regional authorities;

2. Land users and local communities

3. General Public / NGOs / independent experts, opinion leaders;

4. Media;

5. Clients and Consumer organizations (including people having issues with

paying the bills);

6. Business/ branch organizations;

7. Internal Stakeholders (employees, contractors, major equipment suppliers);

8. Other companies within the CEZ Group;

9. Vulnerable people.

Dear Reader/Stakeholder:

If you are not included on the below stakeholder list and wish to receive information about the

2016-2019 Investment Programme, please contact our company by using the contact details

specified in Section 1 of this SEP.

The main stakeholders identified so far are detailed in Table 3.1. below, while their

contact details are provided in Annex 1 . The list will be updated and modified in the

course of the 2016 Investment Programme development to reflect any changes in the

investment programme’s stakeholders (e.g. add new stakeholders).

Table 3-3-1 Identified Groups of stakeholders

Group of Stakeholders Stakeholders

1. State institutions,

administrative bodies and local

authorities

- National /central authorities (e.g: Government,

Ministry of Energy, Ministry of Economy, Ministry

of Environment and Waters, Ministry of Interior,


Group of Stakeholders Stakeholders

relevant Parliamentary committees, state Energy

Regulator (KEVR), National Ombudsman,

Commission for protection of competition,

Commission for protection of consumers, etc)

- Local authorities (e.g: Mayors, Municipal Councils,

District Governors, Regional Environment and

Water Inspectorates etc.)

2. Land users and population of

the villages;

- Villages and localities inhabitants impacted by

implementation of the 2016-2019 Investment

Program

3. General Public, independent

experts, opinion leaders;

- Energy and economy experts;

- Local opinion leaders;

- General public;

4. Media - National media – newspapers, TV, radio, websites;

- Local media;

- Social media;

5. Clients, Consumer

Organizations

- Households (including people having issues with

paying the bills);

- business clients;

- Consumer organizations;

- Civic organizations;

6. Business Organizations - Business organizations and associations;

- Branch organizations;

7. Internal Stakeholders

- Company staff ;

- Contractors and contractors’ staff;

- Major equipment suppliers;

8. Other companies within the

CEZ Group

-CEZ Bulgaria;

- CEZ Electro; - CEZ Trade Bulgaria;

- Varna TPP;

9. Vulnerable people - to be determined

Under point 5 above: A particular interest is for the people with issues in paying the

electricity bills, mainly located in Botevgrad, Dupnitsa, Ihtiman and Samakov. In those

localities, installing the electricity meters at up to 7 meters height was considered in the

past a standard safety measure of CEZ Distribution even before the privatization and,

in the Company’s view, was aimed to reducing the thefts of electricity in risky regions

thus lowering the losses of the Company and preventing unfortunate incidents

endangering human life and health.


Currently, dealing with this issue is part of the long-term communication policy on the

CEZ Distribution. Recently, a strategic management decision was adopted to find

technical solutions in risky regions in order to reduce theft without the need to install

electricity meters at height.

In addition, the Company, with the support of local non-governmental organizations

performs periodic training to the relevant community leaders (including, but not

limited to Roma people) on the best practice to reduce the bills and to save electricity.

Under point 9 above: To date, the Company has not initiated any official identification

of the stakeholders under the “vulnerable people” group.

A recent definition was released by the Ministry of Energy in May 2016. According to

this definition, “Vulnerable customers are households whose members are persons who because

of their age, health or income are at risk of social exclusion in relation to the supply and

consumption of electricity and who are benefiting from measures of social protection to ensure

their necessary electricity supplies”.

CEZ expects also the results of a World Bank Report prepared at the request of the

Bulgarian Government for the Energy sector, aiming to implement a new support

mechanism for vulnerable customers with significantly expanded scope.

These definitions will be further considered by the Company in development and

implementation of the plans and strategies.

In Bulgaria, the last statistics on vulnerable people were produced 2007. In general,

under the vulnerable people group are pensioners, families with many children, low

income families, Roma people, unemployed people, widows, orphans, people with

disabilities and chronical diseases etc.

During the last years, the government analysed various proposals for providing

support to vulnerable people for paying the electricity bills, with allocations varying on

consumption and income. However, to date, none of the proposals was selected and

implemented by the state authorities.

CEZ’s companies in Bulgaria have implemented measures to alleviate all the clients

regardless of their age, income or social group. These measures include various options

for rescheduling of financial obligations towards CEZ. In order to benefit of these

measures, the clients have to contact CEZ’s centers and submit an application form.

Although the current bills for electricity are below the ones in 2013 and salaries

increased (e.g. minimum salary from 158 EUR/month in 2013 to 215 EUR/month in

June 2016), the affordability for the consumers is still an issue to be carefully handled

by the Bulgarian state and by all the distribution companies.

CEZ Distribution does also not expect significant impact of their 2016-2019 Investment

Program on the total price of energy distribution to be applied in the following

regulatory period.


Information disclosure

CEZ companies have a long-term communication program about investments in the

grid which include regular press-releases (on monthly basis), publications of price

proposals during their submission to the Energy and Water Regulatory Committee,

publication of the new prices when they are adopted, interviews with CEZ

representatives and 3rd parties.

Main messages used in answers to media inquiries, interviews and press releases are

the following:

No business can operate at a loss for a long-term period;

Currently CEZ Distribution realize losses from each kWh sold in night tariff

because there is no recognition of actual amount of operating expenses, lowering

the allowable rate of return as well as of the failure to recognize the full amount of

technological losses;

The price for households continues to be significantly lower than the price at

which the company buys energy from National Electric Company AD;

The final decision on prices is in the hands of the regulator;

Retention of approved revenue at current levels would exacerbate the existing

problems in the grid. To overcome them will be required much larger investments

in the future;

Independent experts have estimated that every year about 150 million Leva (BGN)

have to be put in the grid of Western Bulgaria;

CEZ is investing every Lev it receives on the Bulgarian market in the grid;

In its price proposals in the period 2005-2015, CEZ has request the recognition of

investments amounting to 1,335 billion Leva but the State regulator has approved

only about 55% of it or slightly above 737 million Leva. Nevertheless, CEZ has

invested 845 million Leva in the distribution grid - 108 million Leva more than the

approved investments by the Regulator.

CEZ DISTRIBUTION BULGARIA 13 JUNE 2016

4 STAKEHOLDER ENGAGEMENT PROGRAM

The Company has identified specific project information that is to be disclosed to the

majority of the stakeholders groups, as well as the proper means of communication with

each of them.

The analysis of these groups has been performed by the Company based on specific criteria

and resulted in defining the engagement actions to be performed through different specific

approaches including newsletters, periodical updates, newspaper articles, announcements

on community boards, brochures, meetings etc.

The Company has developed the following procedures for establishing clear internal and

external communication:

o Management of internal communication;

o Management of external communication;

o Management of communication in crisis situations;

o Management of Corporate Social Responsibility (CSR activities).

CEZ has prepared and implemented a series of plans meant to provide guidance, planning

and instructions to the personnel in charge with stakeholder engagement within the

Company and programs to communicate the Company’s topics towards external and

internal publics, such as:

o Communication Plans on different business topics;

o Crisis Management Plan incl. Procedures for Issues Management Communication

CEZ Distribution Bulgaria ranks among the 5% of all companies in the World, following

the Investors in People standards for people management.

(https://www.investorsinpeople.com/). Moreover, it is the first company in Bulgaria

accredited on June 6, 2014 with Investors in People Bronze award (bronze medal).

https://www.investorsinpeople.com/

CEZ DISTRIBUTION BULGARIA 14 JUNE 2016

Source: CEZ Distribution

In 2013, CEZ Bulgaria, at its initiative,

has created an organization called “Consumer Council”, which is headed by the

representative of CEZ Bulgaria and in which different consumer, civic and experts

organizations are taking part. CEZ Distribution has its own representative in the Council.

The organisation hosts regular meetings, with participation of NGOs, customers,

regulators, Ministry of Energy etc. During these meetings, the participants discuss topics

such as the means for controlling the electricity consumption, the behaviour to reduce the

energy bills, causes for interruption of energy, metering etc.

For each stakeholder group the anticipated information disclosure needs and means of

communication are summarised in the table 4-1 below.


Table 4-1 Stakeholder Engagement Programme

Information Disclosed or

Engagement Actions

Form(s) of communication Location and

Dates

Target Stakeholders Responsibilities

EIAs outcomes and mitigation

measures considered, in line with

national regulations, only in case

projects within the 2016-2019

Investment Program require EIAs or

AAs (Appropriate Assessments)

Public hearings

Posters, public announcements at local offices of CEZ Distribution and on CEZ Distribution website, according with the requirements of the national regulations.

Community

center the

relevant villages

Local population;

Administrative Bodies and

Authorities

Landowners/farmers in

the project area that may be

directly impacted;

General Public / NGOs /

Independent experts

Mass media

CEZ Distribution in

collaboration with

Environmental

regulatory authority

and EIA/AA

producer

Non-technical summary (NTS)

Environmental and Social Action

Plan (ESAP), Stakeholder

Engagement Plan (SEP), Grievance

Mechanism (*High level or for each

project with significant impact on

local population and/or

environment), for which EIA is

required.

Upload on company website at

http://www.cez-rp.bg

http://www.cez-rp.bg/en/customer-

service/new1708-plan.html

In printed/hard copy form at CEZ

Distribution Customer Services centres

(location and schedule here:


service/where-you-can-find-us.html)

Initial disclosure:

2016

Updated

versions: as

needed, on on-

going and project

basis

General Public and Local

population;

CEZ Distribution

Specific Projects information prior starting any rehabilitation/construction works (leaflets, posters) relevant for local public, in line with national regulations.

Information panels in affected villages for each of the Project in the Investment Programme with significant impact on local population and/or environment, information disclosed on company website, according with the requirements of the national regulations

Information

panels

Disclosed

information

updated as

needed on on-

going basis

Local population

Landowners /farmers in

the projects area

CEZ Distribution

and its construction

contractors

http://www.cez-rp.bg/

http://www.cez-rp.bg/en/customer-service/where-you-can-find-us.html




Engagement Actions


Dates


Leaflets and trainings on energy

savings for reducing the electricity

bills and on risks of unauthorized

electrical works on human health

Communication with local

communities with issues in paying

electricity bills (including but not

limited to roma people) through

different organizations /NGOs or as

suggested by the local administration

Ongoing

basis/as

needed/feasible

People with issues in

paying bills

CEZ Distribution

with support from

local NGOs and

local authorities

Providing the local population

(clients) (especially in areas with

vulnerable people) with information

and guideline on energy savings for

reducing the electricity bills and

state/company support, if applicable



In printed/hard copy form at CEZ

Distribution Customer Services centers

(location and schedule here:


service/where-you-can-find-us.html

Ongoing basis Vulnerable / low income

people

CEZ Distribution

with support of local

authorities/mayoral

ties

Antitheft of electricity and equipment

measures (e.g. investments in grid to

reduce losses and ensure quality of

supply; protection of human life;

equitability principles in paying the bills

for real consumption)

Media publications: articles (press-

releases), interviews; articles by

opinion-makers; reports in main and

local media;

Media workshops / letters/ meetings

with: institutions and local authorities



and facebook

Ongoing basis/as

needed/feasible

Clients; State Institutions;

Local authorities; Media;

Parliament; Regulators;

Opinion leaders; Other

utility companies

CEZ Distribution

Liberalization of the market for LV

end-users. Message: CEZ Distribution

remains the operator of the grid

regardless of choice of end-suppliers. The

tariffs of grid services continue to be

regulated.




local media;





Ongoing basis/as

needed/feasible

Clients: households and

business on LV;

State institutions;

Local authorities;

Opinion leaders;

Experts;

CEZ Distribution








Engagement Actions


Dates


CEZ has the necessary know-how to

operate on an open market with all

participants on it.

and facebook

Improvement in quality of energy

supply. Message: We are investing

every lev in the grid to ensure quality.

We are a hard-working, professional and

customer oriented company. We are

opened and transparent. We are

improving each segment of our work

processes in order to serve customers

better




local media;





and facebook

Ongoing basis/as

needed/feasible

Clients; State institutions;

Local authorities; Media;

State Regulator; Opinion

leaders; Business and

Branch organizations;

Customer organizations

CEZ Distribution

Disruptions by excavation works.

Message: We are a responsible company

abiding to the laws. We are calling the

rules to be respected in order to minimize

the inconvenience for our clients. We are

a trustful partner in providing service to

the population.




local media;

News conference, Round table with

Construction Chamber, letters/

meetings with: institutions and local

authorities



and facebook

Ongoing basis/as

needed/feasible

Clients; Media; Regulator;

Ministry of Energy;

Ministry of Construction;

Construction Chamber;

Opinion leaders;

Construction companies

CEZ Distribution

Preparation for the winter season.

Message: We conduct a voluntary

inspection of power equipment to prepare

it for the increased consumption during

the winter season. We invest a maximum

within our resources to replace or prepare

equipment

Media publications: articles,

interviews; news reports in main and

local media;

Exclusive TV Report; News conference,

media workshop,



Yearly, on Q3 Clients; Institutions; Local

authorities; Media; State

Regulator; Opinion

leaders; Consumer

organizations

CEZ Distribution






Engagement Actions


Dates


and facebook

Simplification of procedure for

connecting new clients to the grid.

Message: We are a hard-working,

professional and customer oriented

company.

We are improving each segment of our

work processes in order to serve

customers better.

Media publications: articles,

interviews; news reports in central and

regional media;



and facebook.

Consumer Council meeting.

Ongoing basis/as

needed/feasible

Clients: business and

domestic;

Institutions; Regulator;

Construction Chamber;

Construction companies;

Business and Consumer

organizations

CEZ Distribution

General support to and engagement

with local communities

Direct communication with local

administrations

Ongoing

basis/as

needed/feasible

Local population CEZ Distribution

and its construction

contractors

*High level ESAP, NTS and SEP refers to current documents produced by ERM, an independent international consulting firm, as part of the 2016

ESDD for the 2016-2019 Investment Program. Similar with these general documents, CEZ Distribution will produce ESAPs, NTSs and SEPs for each of

the major (with impact on socio-economic and environment) project in the 2016-2019 Investment Program, for which an EIA is required.



5 GRIEVANCE MECHANISM

Reporting Grievances

CEZ Distribution has implemented an Internal Grievance Procedure (called Directive

No.78/2011) allowing for appropriate stakeholder grievance management. The

Directive addresses the process of receiving, recording, investigation, resolution,

reporting and response to grievances and is interconnected with other specific

procedures implemented at the Company.

A grievance is an actual or perceived problem or other issue related to a project of

the investment programme that might give grounds for complaint by a member of

the public or other stakeholders. As a general policy, the Company will work pro-

actively towards the prevention of grievances through the implementation of impact

mitigation measures and community liaison activities that enable CEZ Distribution to

anticipate and address potential issues before they become grievances

Nevertheless, should grievances emerge, the Company is committed to addressing

these in a timely and effective manner in accordance with the national legislation,

international best practice and the Company's Internal Grievance Procedure.

A Public Grievance Form (provided in Annex B of this document) should be

completed by anyone wishing to lodge a grievance in written form. The form

comprises fields for (i) the name and contact details of the person lodging the

grievance (for the purposes of enabling communication on grievance process and its

resolution) including preferred means of communication, (ii) description of the

grievance/incident, (iii) the date when the grievance/incident occurred, (iv)

grievance resolution outcome expected by the person lodging the grievance, (v)

grievance categorization and (vi) indication on the expected resolution time as per the

Company procedure.

This Form is to be made available in Bulgarian language at Company’s Customer

Services Centres in all the ten regions in Western Bulgaria and on the website.

All grievances submitted to the Clients Servicing Centres have to comply with the

following requirements:

To be written in Bulgarian;

To include the name and address of the person lodging the grievance;

To be signed by the person lodging the grievance;

To include clear description of the grievance/request;

To include details on the specific case as well as evidences if available;

Place of electricity consumption if the grievance is related to a specific object of electricity consumption.


Grievances that do not comply with the above requirements are also accepted and

registered (e.g. anonymous), but their resolution may take longer time. In case a

grievance includes a phone number as contact details, the CEZ employees will call

and request additional details on the case in order to clarify the circumstances

described in the grievance.

All grievances are registered in the Clients Information System (CIS) - SAP business

operations and customer relations software system - and receive unique reference

numbers. Responsibilities are defined for each process stage.

In case the grievance is submitted in other format, the CEZ employee receiving the

appeal will fill in all the data in the designated Grievance form and will assure its

registration in the CEZ grievance system CIS.

The Grievance Procedure will be advertised on company website at http://www.cez-

rp.bg and on printed / hard copy forms at CEZ Distribution Customer Services

Centres.

How to Register a Grievance?

There are several ways that a grievance will be able to be registered:

By sending a completed Grievance Form to our headquarter at 159 Tsarigradsko Shose Blvd. Sofia 1784;

By sending a completed Grievance Form to one of our offices: (Addresses and schedule here: http://www.cez-rp.bg/en/customer-service/where-you-can-find-us.html);

By sending an email to the following address: [email protected];

By calling our company at: 0700 10 010 (hotline) or by sending a fax to (02) 8959 667;

By web portal at: http://www.cez-rp.bg/edee/qf/en/ramjet/cez-rp/contact-us/formPage .

In addition to the above mentioned requirements, the grievances submitted to the

dedicated email address ([email protected]) should include information on the

preferred means of communication.

Confidentiality

Some grievances may be raised in confidence under this procedure. Grievances will

not be disclosed without the consent of the stakeholder.

Grievance Procedure

CEZ Distribution handles grievances received in line with the Directive No.78/2011

implemented at the Company. Directive No.78/2011 includes a separate section

related to grievances received from governmental institutions.






http://www.cez-rp.bg/edee/qf/en/ramjet/cez-rp/contact-us/formPage

http://www.cez-rp.bg/edee/qf/en/ramjet/cez-rp/contact-us/formPage



The procedure addresses the process of receiving, recording, investigation,

resolution, reporting and response to grievances received and is interconnected with

other specific procedures implemented at the Company. Responsibilities are

appropriately defined for each process stage. The procedure also provides for

continuous improvement based on feedback from all involved in handling the

grievance process.

The current Grievance Procedure is very general and mainly customers oriented. This

is to be revised to specify that covers also environmental, social, land use,

biodiversity, cultural heritage and other non-customers related topics and situations.

Five process streams are defined for handling the grievances, pending on how the

grievance is received: (i) by email or by fax, (ii) by regular mail or in person/verbal,

(iii) through the call centre/hotline, (iv) through the client relations centre or (v)

through the web portal.

In all cases, once received, a grievance is registered, managed and tracked using the

SAP business operations (Clients Information System (CIS) used and operated by the

Company.

Along with the filling in of the relevant information in the CIS, the responsible

department/person for the specific grievance is defined. The grievance is then

forwarded to that department/authorized person for resolution which will distribute

it to appropriate responsible. Employees of Customer Service Department are in

charge with the monitoring of the process of answering the grievance and the

deadline to communicate the resolution to the appellant. Once the person in charge

with solving the grievance prepares the answer, this is forwarded to the authorized

his immediate superior manager for review and approval/signature. Based on the

approved statement, the employees of Customer Service Department prepare an

answer to the person lodging the grievance. There are additional steps in the

grievance resolving process for the cases when there are clients’ claims for

compensations for damages, complaints related to poor quality of the supplied

electricity or in other cases on higher difficulty.

The term for answering to the written grievance is of 21 days, with the exception of

the grievances received from authorities when the deadlines are shorter (2 to 7 days,

depending on applicable legislation).


Recording Phase Resolution Phase Monitoring Phase

Grievance

recording

and

allocation

Classification Analysis

and

resolution

Response to

grievance

Reporting and

evaluation

Grievance

receipt

(through five

possible

streams

Grievance

allocation to

the relevant

grievance

administrator

and

recording in

SAP system

Grievance

classification

by grievance

administrator

Assignment

of resolution

deadline

(with

consideration

of legal

requirements

when

applicable)

Grievance

allocation

to relevant

employee

or

Company

department

for analysis

and

resolution

Grievance

analysis

and

resolution

Preparation

and

provision of

response to

grievant

Grievance

closure

Periodic monitoring

based on key

performance indicators

(KPI) when applicable,

reporting, continue

process improvement

In period 2010-2016, there were 60,900 grievances registered by the Company,

focused almost exclusively on the issues directly connected to distribution of the

electricity (meters functioning, damages to the powerlines, quality of electricity,

licenses, quality of services, theft of electricity, facilities for purchase electricity,

overcharged recuperation, invoicing etc). There was no information available

whether any of those grievances was also sent to court of justice for resolution.

Workers’ Grievances

The grievance mechanisms regarding working conditions and attitude of employees

are in compliance to current legislation in Republic of Bulgaria (Labor Code, Law for

protection of discrimination, labour safety conditions regulations, etc.) and internal

rules and procedures.

The steps in the formal process are the following:

submission of the complaint to HR department, leadership of the company or to the line manager;

Assignment of an independent Commission for Investigation of the complaint;

Review of the complaint and its grounds and priority;


Meetings, evidence collections, interviews with involved employees (including employee who has submitted the complaint)

Preparation and submittal of the proposed resolution to the management board of the Company with final conclusions and opinion of the Commission for Investigation.

Feedback to the employee who has submitted the complaint.

If preferred by the complainant /if considered more feasible / in case of sensitive

issues, it is also an option to address the grievances by having informal discussion

and escalation of working issues with the line manager and HR department. In

addition, three psychologists were recently hired by CEZ as part of the newly opened

unit Internal Assessment Centre. The scope of this unit is evaluation and

development of the managerial positions and employees. Although their role is

mainly related to organizational psychology as opposed to addressing conflicts, in

sensitive cases, the psychologists may also provide support and expertise upon need.

The period of time for providing a resolution depends on its complexity, but will be

done in a reasonable period of time (in case no detailed investigations are needed, up

to 30 days).

In 2015 there were four written grievances registered by the CEZ employees. These

refer to complaints on the line managers, bonuses system, discrimination and sexual

harassment and all were solved internally, without escalating the case to the court

and without any complains or risks on violation of the human rights.


Annex A

Stakeholder Contact Details


Name Contact details Responsibility /

Involvement in the

project/project area (if

applicable)

State institutions, administrative bodies, regulator, national ombudsman, local

and regional authorities

Independent experts/opinion leaders /NGOs

Media

Consumer Organizations

Business / Branch Organizations

Major equipment suppliers and contractors

Other companies within the CEZ Group


Annex B

Public Grievance Form


PUBLIC GRIEVANCE FORM

Reference No:

Full Name

Contact Information

Please mark how you wish to

be contacted (mail,

telephone, e-mail).

By Post: Please provide mailing address: ______________________________________________________________________________________________________________________________________________________________________________

By Telephone: _______________________________________________

By E-mail _______________________________________________

Preferred Language for

communication Bulgarian

Other, please specify: ___________________

Description of Incident or Grievance: What happened? Where did it happen? Who did it happen

to? What is the result of the problem?

Date of Incident/Grievance

One time incident/grievance (date _______________)

Happened more than once (how many times? _____)

On-going (currently experiencing problem)

What would you like to see happen to resolve the

problem?

Signature:_______________________________

Date: ______________________________

Please return this form to: Customer Service Department

CEZ Distribution Bulgaria AD

Address: 1784 Sofia 195 Tsarigradsko shosse Blvd. ; e-mail: [email protected]

We will register your complaint and provide an answer within up to 21 calendar days.


Documents

Stakeholder Engagement Plan€¦ · 1.4 General Social Context ... mass media. During the hearings, any participant has the right to express his or her opinion, ... External stakeholders